María Carmen Moreno Lerma, Food Contact and Packaging Group Leader, and Nuria García Batista, Chemical Characterization Laboratory Researcher, both of AIMPLAS, can confirm that plastic food packaging is safe.
As consumers, we are increasingly worried about the safety and quality of the packaged food we buy. We want nutritious food and safe food packaging. We have all read about phthalates and bisphenols and the effects of their consumption on human health. Concern is now growing about the migration of packaging substances into foodstuffs. And consumer concern increases when this packaging is made of plastic, despite the fact that plastic is the most controlled material for food contact at European level, which means it is placed on the market based on maximum guarantees of safety.
In fact, the European Commission is currently reviewing the legal framework applied to all materials intended to come into contact with food, Regulation (EC) No. 1935/2004[1], because it acknowledges that the regulation requires updating and that there are materials other than plastic (e.g. metal, wood, paper and cardboard) which food safety is difficult to verify through application of the regulation.
This regulation also includes the possibility of establishing specific measures for each type of material in order to ensure compliance with the basic principles established. However, plastics are the only materials that have their own fully developed legislation. These specific measures are developed in Commission Regulation (EU) No. 10/2011[2] and its subsequent amendments, and establish the requirements that raw materials and finished products must meet. In addition, its Annex IV describes the information that must be included in the declaration of compliance (a key document for the transmission of all information necessary for compliance with Regulation 10/2011 in the supply chain).
Regulation 10/2011 also indicates the substances (additives, monomers, etc., previously evaluated by the European Food Safety Authority (EFSA)) whose use is allowed in plastic for food contact (requirement for raw materials). It is therefore necessary to verify, from the starting point of the manufacture of raw materials, that all substances are authorized or permitted and that this information, together with any applicable restrictions, is transmitted along the entire manufacturing chain by means of the declaration of compliance mentioned above. In the manufacture of food packaging, substances are used whose safety has already been verified. But it is the final product manufacturer’s responsibility to verify that the amount present in the packaging or that may be transferred to the food via migration is within the limits determined to be safe for consumers.
In addition to permitted substances, non intentionally added substances (NIAS) present in materials other than the plastic used in manufacture must also be considered, such as impurities present in substances used in manufacture, as well as reaction and/or degradation products formed during packaging manufacture and use. Although these substances are not included in the EU list, they are subject to risk assessment to verify compliance with the non-toxicity requirement of the Framework Regulation. This risk assessment is based on evaluating not only the toxicity of a substance, but also the level of exposure to it because risk depends on toxicity and time of exposure.
Therefore, in terms of the assessment of the compliance of plastic products for food contact, in addition to new requirements for the known components (formulation) of plastics, there has been a gradual increase among end customers in requirements regarding the analysis of NIAS. In fact, plastic leads the way in safety compared to other materials and boasts different working groups (e.g. ILSI Europe, the International Life Science Institute; EuPIA[3], the European Printing Ink Association; and the Italian Institute of Packaging[4]) that try to shed light on the topic and, above all, standardize the protocol to be followed by publishing different guidance documents that sum up the efforts of manufacturers to assess NIAS in materials intended for food contact.
Legislation requirements are reviewed periodically (in fact, the Framework Regulation is currently being reviewed and the 15th amendment of Regulation 10/2011 is expected to be released this summer) to adapt to new materials and/or restrictions that may arise. In addition, as mentioned, not only is it verified that the amount of additives, monomers, etc. added during manufacture of the packaging do not migrate into the food, but substances not intentionally added during manufacture of the packaging are also tested for compliance with the non-toxicity requirement.
Plastic is therefore the best option for foodstuffs that must be packaged to be protected from degradation due to external factors (e.g. temperature, light, moisture), as well as contamination by odours, microorganisms and dust, given updated legislation and a series of scientific protocols applicable to the current manufacturing system to ensure the harmlessness of plastic packaging intended to come into contact with food.
[1]REGULATION (EC) No. 1935/2004 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 October 2004 on materials and articles intended to come into contact with food.
[2]COMMISSION REGULATION (EU) No. 10/2011 of 14 January 2011 on plastic materials and articles intended to come into contact with food.
[3] EuPIA Guidance for Risk Assessment of Non-Intentionally Added Substances (NIAS) and Non-Listed Substances (NLS) in printing inks for food contact materials. 2017
[4] Guidelines to assess the safety of NIAS and non-evaluated substances: Risk assessment, management and suggestions for the FCM supply chain. 2018